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Chapter 4700

FEDERAL ENTITY REPORTING REQUIREMENTS FOR THE FINANCIAL REPORT OF THE UNITED STATES GOVERNMENT

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This Treasury Financial Manual (TFM) chapter prescribes how federal entities provide data for the Financial Report of the United States Government (FR) using the Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS) along with additional details from the audited department-level financial statements. This chapter also includes a listing of the federal entities included in the FR, Intra-governmental Transactions (IGT) process, and requirements for submitting pre-closing GTAS Adjusted Trial-Balance (ATB). Please refer to Office of Management and Budget (OMB) Circular No. A-136 for the reporting requirements for federal entities' audited financial statements.

This TFM chapter does not include all reporting requirements for GTAS. Additional information can be found on the GTAS website.

Section 4701—Scope and Applicability

All federal entities must provide Fiscal Service with the required fiscal year-end data that is used to prepare the FR. All federal entities (significant or other) must submit GTAS ATB data and manual adjustments to reconcile to the federal entity’s audited department-level financial statements and the reclassified financial statements, which provides the connection to the data in the FR. Reclassified financial statements represent the government-wide financial statement format. GTAS will crosswalk the GTAS ATB data to the financial statement line items based on USSGL crosswalks. The statements are system-generated using GTAS ATB data and manual adjustments. Please refer to Note 44 of OMB Circular No. A-136 for details on the reconciling between the federal entity’s audited financial statement and the reclassified financial statements.

The Chief Financial Officer (CFO) or CFO’s designee of each significant entity must review the approval of manual adjustments in GTAS, journal vouchers processed at the government-wide level on the federal entities audited data, and intra-governmental certifications. Fiscal Service will send a data call to the 40 significant entities, and select other entities, requesting that the CFO of each federal entity designate the certifying officials for various required year-end functions. The CFO certifications form, which lists each designee from the data call, must be signed by the federal entity’s CFO.

Federal entities must submit pre-closing GTAS ATB via the GTAS application. Federal entities must submit a GTAS ATB for each Treasury Account Symbol (TAS) level using proprietary and budgetary USSGL accounts. See the USSGL website for current fiscal year (FY) reporting.

Fiscal Service compiles the information from the GTAS submissions for all federal entities into the government-wide financial statements. The Balance Sheet is a financial statement with an agreed upon set of standardized financial statement lines between the department-level and government-wide financial statements. The Statement of Net Cost (SNC) and the Statement of Operations and Changes in Net Position (SOCNP) are not standardized; therefore, they are referred to as reclassified financial statements (Balance Sheet, reclassified SNC, and reclassified SCNP) that are included in the consolidated FR. 

Significant Entities with a year-end other than September 30 are subject to alternate audit procedures and Treasury reporting as outlined in subsection 4705.40 below.

Please refer to subsection 4705.30d of this chapter and OMB Circular A-136 for supplemental information on sustainability financial statements.

Reporting requirements in this chapter are grouped as follows:

  • Section 4705 includes FR data requirements,
  • Section 4708 includes intra-governmental requirements, and
  • Section 4709 includes GTAS requirements.

4701.10—Reporting Entity

Purpose

To provide the Federal Accounting Standards Advisory Board’s (FASAB) Statements of Federal Financial Accounting Standards (SFFAS) No. 47, Reporting Entity determinations received by the federal entities, reviewed by the Working Group, and approved by the SFFAS No. 47 Steering Committee. The determinations are listed in Appendix 1b (Consolidation Entities, Disclosure Entities, and Related Parties).

Background

An initial questionnaire was designed for implementation by compiling the key deciding factors throughout FASAB Standard No. 47 with the corresponding paragraphs in SFFAS No. 47 with each question. The questionnaire asked for the component reporting entity to be identified. Upon completion of the survey, the entity was led to a reporting determination of consolidation entity, disclosure entity, related party, or not required to report. For FY 2020, consistent with Appendix C of SFFAS No. 47, the survey now requires component entities to document the rationale for their determinations as to other entities for each entity considered. It also requires entities to specify whether any other entities are component thereof (i.e., consolidation or disclosure), a related party or do not meet the criteria of SFFAS No. 47.

The survey supported the following determinations*:

  • Component Reporting Entity—is used broadly to refer to a reporting entity within a larger reporting entity. Examples of component reporting entities include organizations such as executive departments, independent entities, government corporations, legislative entities, and federal courts. Component reporting entities would also include sub-components (those components included in the financial statements of a larger component reporting entity) that may themselves prepare financial statements. An example would be a bureau that is within a larger department that prepares its own stand-alone financial statements.
  • Consolidation Entity—is an organization that should be consolidated in the financial statements based on the assessment of whether it: “(a) is financed through taxes and other non-exchange revenues, (b) is governed by the Congress and/or the President, (c) imposes or may impose risks and rewards to the federal government, and (d) provides goods and services on a non-market basis.” It also includes organizations that, if excluded would, result in misleading or incomplete financial statements.
  • Disclosure Entity—is an organization with a greater degree of autonomy within the federal government than a consolidation entity.
  • Related Party—Organizations are considered to be a related party in the financial statements if the existing relationship or one party to the existing relationship has the ability to exercise significant influence over the other party’s policy decisions. It is noted that failing to note the relationship would be misleading (such as relationships considered for inclusion under consolidation/disclosure, but which have been determined not to meet the inclusion principles).

*See SFFAS No. 47, Reporting Entity for more detail.

The top down approach was used to identify potential entities that meet the criteria of SFFAS No. 47 from a government-wide perspective. To ensure completeness, the component should perform a bottom up assessment to identify entities that may not have been identified through the top down approach. Each component entity should perform an entity review annually to validate proper reporting at the entity level. For assistance in an entity level review, please contact Fiscal Service at GTAS.Team@fiscal.treasury.gov to receive the SFFAS No. 47 Entity Analysis Excel workbook. Notify Fiscal Service immediately if an entity analysis results in a determination(s) that differs from those outlined in Appendix 1b, and include the basis for determination.

Component entities must notify Fiscal Service of any discrepancies between the auditor and the component entity as to the component entity’s reporting entity status determination. In addition, questions concerning which component entity a federal entity needs to be consolidated into must be discussed with Fiscal Service. Final reporting entity determinations must be agreed upon by Treasury and OMB.

Procedure/Requirements

Federal entities must report information based on the SFFAS No. 47 determination. The determinations are available in Appendix 1b and will be used to report Appendix A: Reporting Entity of the Financial Report of the United States Government.

An entity with the determination of consolidation will submit an ATB in GTAS. This data will flow to the face of the government-wide statements presented in the FR.

SFFAS No. 34 recognizes that some federal reporting entities prepare and publish financial reports pursuant to the accounting and reporting standards issued by the Financial Accounting Standards Board (FASB). SFFAS No. 34 provides that certain entities' financial statements prepared in conformity with accounting standards issued by the FASB may be regarded as in conformity with generally accepted accounting principles (GAAP). Consolidation entities (that is, the consolidated government-wide reporting entity or a consolidated component reporting entity) may consolidate component or sub-component reporting entity financial statements prepared in accordance with SFFAS No. 34 without conversion for any differences in accounting policies among the organizations.

Entities with a determination of disclosure or related party (see Appendix 1b) will continue to report Treasury Account Symbols (TAS), if applicable, but when utilizing the disclosure or related party, TAS transactions must be processed as non-federal (N). This information is reported by the consolidation entities and not a direct report by the disclosure or related party. Therefore, if the entity has a relationship with a disclosure entity included in the government-wide financial statements or related party, make sure to report the federal or non-federal designation as non-federal.

Section 4702—Authority

Section 405 of the Government Management Reform Act of 1994 [31 U.S.C. 331(e)(1)] requires that the Secretary of the Treasury annually prepare and submit to the President and the Congress an audited financial statement for the preceding FY. This statement must cover all accounts and associated activities of the executive branch of the federal government. Section 114(a) of the Budget and Accounting Procedures Act of 1950 [31 U.S.C. 3513(a)] requires each executive branch agency to furnish financial and operational information as the Secretary of the Treasury may stipulate.

Treasury and OMB consolidate the legislative and judicial branches in the consolidated financial statements as well. To ensure that all material amounts across the three branches of government are accounted for, Fiscal Service uses the data submitted in GTAS plus records supported journal vouchers based on audited financial statements, as well as the authoritative data from the Central Accounting Reporting System (CARS).

Section 4703—Definition of Terms

Active Treasury Account Symbol—Any Treasury Account Symbol (TAS), regardless of balances or transaction activity, that has a TAS status of “U-Unexpired” or “E-Expired.” Exceptions include situations such as available receipt accounts (balances are rolled into the expenditure main account), the TAS in the 7XXXXX main account series (not brought into the Super Master Account File (SMAF)), and the TAS that should have canceled but did not due to outstanding balances or other issues.

Adjusted Trial Balance (ATB)—This is a list of USSGL accounts with attributes and pre-closing adjusted balances prepared at a specified date (i.e., year-end). Federal entities submit GTAS ATB by the TAS, which includes USSGL accounts with attributes. The USSGL account balances should reflect pre-closing adjusting entries. The total sum of the debit balances must equal the total sum of the credit balances in the ATB for each TAS. The ATB intra-departmental balances, for the federal entity, must eliminate. Federal entities must include the required attributes with the appropriate USSGL accounts (see the USSGL website for current year reporting requirements). 

Agency—See definition for Entity.

Agency Financial Report (AFR)—This report summarizes a federal entity’s accomplishments relative to its performance goals and objectives, and provides an overview of its finances and operations for each fiscal year. It includes four sections: Management’s Discussion and Analysis, Financial Section, Other Information, and Appendices.

Agency Identifier (AID)—An Agency Identifier is a three-digit code of the component TAS format. The code is assigned based on who is designated as the reporting entity for the established TAS. This can differ from the authoritative entity listed in the legislation.

Attribute—An attribute is a modifier that further describes a USSGL account to meet a specific reporting requirement. Federal entities capture this information at the transaction level. The USSGL website contains applicable GTAS attributes for the current and next fiscal year reporting. 

Budget Subfunction Code (BSF)—Budget Subfunction Code is a three-digit GTAS code that classifies budget resources by function and subfunction. It groups budget authority and outlays of budget and off-budget federal entities in terms of the national needs being addressed. For a complete list of BSF codes (also known as functional classification codes), see OMB Circular No. A-11.

Business Event Type Code (BETC)—A Business Event Type Code is up to an eight-character code that indicates the type of activity being reported (borrowing, repayment, offsetting collection, receipt, disbursement, etc.). It is used in combination with the TAS to determine the transaction effect on the Fund Balance with Treasury.

Calendar Year-end Entity—A calendar year-end entity is a federal entity that operates on a calendar year basis that are considered significant to the FR if they have a line item or note disclosure that is equal to or greater than $1 billion, but are only required to have audit assurance on line items or note disclosures that contribute to the top 95% of the total FR line item data.

Central Accounting Reporting System (CARS)—The Bureau of the Fiscal Service’s central accounting reporting system for budget execution, accountability, and cash/other asset management as reported by federal program entities. 

Combined Presentation—A combined presentation must reflect an entity’s balance prior to any intra-governmental eliminations. Eliminations within a main account/fund family should be performed. However, intra-governmental activity, such as transfers, within the FR Entity between different main accounts/fund families must not be eliminated.

Entity—An entity is a federal government agency, program, corporation, commission, or board; which exercises disbursing functions under specific statutory authority, or authority delegated by Treasury. “Agency”, “Federal Agency”, “department”, “federal entity”, and “reporting entity” are used interchangeably unless otherwise noted. See Appendices 1a and 1b for a complete listing as well as Appendix A of the FR.

Fiduciary Fund Accounts—The SFFAS No. 31, Accounting for Fiduciary Activities defines a fiduciary activity as “activity a federal entity collects or receives and subsequently manages, protects, accounts for, invests, and/or disposes of cash or other assets in which non-federal individuals or entities (or “non-federal parties”) have an ownership interest that the federal government must uphold. Non-federal parties must have an ownership interest in cash or other assets held by the federal entity under provision of law, regulation, or other fiduciary arrangement. The ownership interest must be enforceable against the federal government. Judicial remedies must be available for the breach of the fiduciary obligation.”

Treasury Account Symbols that are designated as fiduciary, per SFFAS No. 31, should be reported as non-federal. Please note that most fiduciary funds are Deposit Funds.

Fiduciary Transactions—Fiduciary transactions are intra-governmental transactions that consist of Fiscal Service investments and borrowings; Federal Financing Bank (FFB) borrowings; Department of Labor (DOL) employee benefit transactions; and Office of Personnel Management (OPM) employee benefit transactions.

It is noted the word “fiduciary” is used in a different context than used in Statements of Federal Financial Accounting Standards (SFFAS) No. 31, Accounting for Fiduciary Activities, discussed in subsection 4705.30e.

Financial Report of the United States Government (FR)—The Financial Report of the United States Government provides the President, Congress, and the American people with a comprehensive view of the federal government's finances, i.e., its financial position and condition, revenues and costs, assets and liabilities, and other obligations and commitments. The FR also discusses important financial issues and significant conditions that may affect future operations.

Financial Reporting Entity (FR Entity) Code—The Financial Reporting Entity Code is a four-digit code representing individual federal entities in GTAS that denotes reporting responsibility for federal entity financial statements, ATB data, and intra-governmental data in GTAS. 

General Fund Receipt Account (GFRA)—A receipt account credited with all funds from collections that are not identified by law for another account for a specific purpose. These collections are presented in the President’s Budget of the United States Government as either governmental (budget) receipts or offsetting receipts. These include taxes, customs duties, and miscellaneous receipts. There are numerous General Fund Receipt Accounts that are described in the Federal Account Symbols and Titles (FAST) Book. See the FAST Book website for more information. 

Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS)—GTAS is used by federal entities to submit a pre-closing ATB for proprietary and budgetary data simultaneously in one bulk file submission.

Intra-departmental Balance—An intra-departmental balance is a USSGL account balance resulting from a transaction between TASs assigned to the same federal entity.

Intra-governmental Transactions or Balances—Intra-governmental transactions or balances resulting from business activities conducted by two different consolidation federal entities included in the FR.

Management Representation Letter (MRL)—The Management Representation Letter is a letter addressed to a federal entity’s external auditor, signed by senior management. The letter attests to the accuracy of the financial information that the federal entity has submitted to the auditors for their analysis.

Performance and Accountability Report (PAR)—The Performance and Accountability Report consists of the Annual Performance Report (APR) required by the Government Performance and Results Act (GPRA), as amended; annual financial statements; and other reports such as entities’ assurances on internal control, accountability reports by entity heads, and Inspectors General’s assessments of entities’ most serious management and performance challenges.

Probable Likelihood of Loss—Probable Likelihood of Loss implies that the future event or events are more likely than not to occur, with the exceptions of pending or threatened litigation and unasserted claims. For pending or threatened litigation and unasserted claims, the future confirming event or events are likely to occur. If a negative outcome is probable, the federal entity must record a liability on its books for the estimated amount of loss. The estimated liability may be a specific amount or a range of amounts. If some amount within the range is a better estimate than any other amount within the range, then the federal entity should recognize that amount as a liability and should disclose the range of possible loss as well as the nature of the contingency in its financial statement notes. If no amount within the range is a better estimate than any other amount, then the federal entity should recognize the minimum amount in the range as a liability and should disclose the range and a description of the nature of the contingency in its financial statement notes. See Federal Accounting Standards Advisory Board (FASAB) Statement of Federal Financial Accounting Standards (SFFAS) Nos. 5 and 12.

Reasonably Possible Likelihood of Loss—Reasonably Possible Likelihood of Loss implies that the chance of the future event or events occurring is more than remote but less than probable. If it is reasonably possible that the federal entity will incur a loss, the entity must disclose the nature of the contingency and an estimate of the possible liability, an estimate of the range of the possible liability, or a statement that such an estimate cannot be made (see SFFAS Nos. 5 and 12).

Reciprocal Category (RC)—A Reciprocal Category is a set of reclassified financial statement federal line items or a grouping of USSGL accounts. The set is used to perform eliminations at the government-wide level (see Section 4705 and Appendices 2 and 3).

Reclassified Financial Statement—The reclassified financial statement represents the government-wide financial statement format. GTAS will crosswalk the GTAS ATB data to the reclassified financial statement line items (for the Balance Sheet, Reclassified SNC, and Reclassified SCNP) based on the USSGL crosswalks. The statements are system-generated using GTAS ATB data. Please refer to Note 44 of OMB Circular No. A-136 for details.

Remote Likelihood of Loss—Remote Likelihood of Loss implies that the chance of the future event or events occurring is slight. If only a remote chance of loss is possible, the federal entity need not record a liability nor provide a note disclosure (see SFFAS Nos. 5 and 12).

Reporting Entity—The Reporting Entity refers to the federal entities for inclusion in the FR. Terms for these organizations (such as agencies, entities, department, corporations, non-profits, bureaus) may be used interchangeably with the term Federal Entity, unless otherwise noted (see Appendices 1a and 1b). The Reporting Entity list can be found in Appendix A of the FR.

Guidance for what organization should be reported upon by a reporting entity is in the SFFAS No. 47, Reporting Entity and subsection 4701.10 of TFM Volume I, Part 2, Chapter 4700, which is effective for the current FY.

Reporting Type Code—The Reporting Type Code refers to the designation of a TAS. A TAS is either designated as E-Dedicated Collections, F-Fiduciary, or U-Undesignated by Treasury in both CARS and GTAS. If the fund is designated as E, it is consolidated in the FR and it is also, designated as part of the Funds from Dedicated Collections footnote. If the fund is designated as F, it is not consolidated in the FR and it is only included in the Fiduciary Activities footnote. If the fund is designated as U, it is consolidated in the FR and included in all applicable footnotes.

Significant Entities—Significant entities are federal entities consisting of the CFO Act entities and additional entities identified by Treasury that are material to the FR. Federal entities are deemed material to the FR if they have data that feeds to reclassified financial statement line items or note disclosures that are greater than $1 billion. Significant entities with a year-end other than September 30 (i.e. calendar year-end) are subject to all requirements of this TFM chapter as well as alternate audit procedures as outlined in subsection 4705.40. See Appendix 1a for the complete list of significant entities.

Special Fund Receipt Accounts—Special Fund Receipt accounts credited with funds from collections that are identified by law but included in the federal funds group rather than classified as trust fund collections. These collections are presented in the President’s Budget as either governmental (budget) receipts or offsetting receipts.

Statements of Changes in Net Position (SCNP) —The Statements of Changes in Net Position report the changes in an entity’s net position during the reporting period, which results from changes to Unexpended Appropriations and Cumulative Results of Operations.

Statements of Operations and Changes in Net Position (SOCNP) —The Statements of Operations and Changes in Net Position report the results of government-wide operations and net operating costs, which include the results of operations for funds for dedicated collections. They include non-exchange revenues, which are generated from transactions that do not require a government entity to give value directly in exchange for the inflow of resources.

Summary of Uncorrected Misstatements (SUM)—The federal entity’s auditor should communicate factual, projected, and judgmental misstatements identified during the audit to the appropriate level of management and those charged with governance, as required by AU-C 450 and AU-C 260. The auditor should request management to correct all factual misstatements. If management corrects one or more of the identified misstatements to the financial statements, the auditor should use the SUM (before discussion with management) to create a new SUM (after discussion with management) for any remaining uncorrected misstatements. The auditor should attach the SUM without the auditor’s calculations, evaluation, and conclusion (or a listing of uncorrected misstatements if the number and amount of the misstatements are insignificant) to the management representation letter as discussed in Financial Audit Manual 1001.

Super Master Account File (SMAF)—The Super Master Account File contains the valid TAS balances and attributes used for budgetary and proprietary ATB submissions. See the GTAS website for more information. 

Trading Partner Agency Identifier (TPAID)—The Trading Partner Agency Identifier is a three-digit bulk file attribute used to identify the reporting entity’s trading partner (see Appendices 1a and 1b).

Trading Partner (TP)—A Trading Partner is a federal entity that is party to intra-governmental transactions with another federal entity.

Trading Partner Code—A Trading Partner code is the bulk file attribute used to identify the trading partner entity (see Appendices 1a and 1b). This consists of the TPAID and the Trading Partner Main Account (TPMA).

Trading Partner Main Account (TPMA)—The Trading Partner Main Account is a four-digit bulk file attribute used in conjunction with the Trading Partner Agency Identifier (TPAID) to identify the reporting entity's trading partner.

Treasury Account Symbol (TAS)—The Treasury Account Symbol is an identification code assigned by the Department of the Treasury. The TAS represents individual appropriations, receipts, and other fund accounts. 

Treasury Appropriation Fund Symbol (TAFS)—The Treasury Appropriation Fund Symbol is a combination of numbers denoting the responsible federal entity, period of availability, and fund classification according to a prescribed system of account classification and identification. A TAFS is a subset of a TAS. A TAFS has budgetary USSGL accounts and is used to report budgetary authority.

United States Standard General Ledger (USSGL)—The United States Standard General Ledger provides a uniform Chart of Accounts and technical guidance to be used in standardizing federal entity accounting. See the USSGL website for more information.

Section 4704FR Reporting and Submission Dates

See Figure 2 for the FR reporting and submission dates regarding GTAS, intra-governmental transactions/balances, legal representation letters, Management Representation Letters (MRLs), and subsequent events.

4704.10—Third Quarter Reporting (Unaudited Financial Statements and Notes)

The purpose of these submissions is to enable Fiscal Service to conduct preliminary analysis on federal entity data to facilitate preparation of the FR.

Federal entities must submit unaudited interim financial statements 21 business days after the end of third quarter. Comparative interim financial statements are limited to the Balance Sheet, SNC, and SCNP. Along with the three financial statements, federal entities must submit a variance analysis in accordance with OMB Circular No. A-136, Section IV.2. In addition, federal entities must submit a completed Budget Deficit Reconciliation template. The above deliverables, along with unaudited notes must be submitted 45 business days after the end of third quarter (see Figure 2 for all due dates). All applicable documents are to be transmitted through MAX.gov, but may also be transmitted directly to Fiscal Service in accordance with Fiscal Service requests. Fiscal Service will also require federal entities’ assistance with completing the analysis of notes that present a greater risk of failing to meet the prescribed disclosure requirements. Examples of these notes are: 

  •   Cash and Other Monetary Assets,
  •   Loans Receivable and Loan Guarantee Liabilities, Net,
  •   Federal Debt Securities Held by the Public and Accrued Interest,
  •   Federal Employee and Veteran Benefits Payable,
  •   Contingencies,
  •   Social Insurance,
  •   Property, Plant, and Equipment, Net,
  •   Disclosure Entities and Related Parties,
  •   Insurance and Guarantee Program Liabilities,
  •   Fiduciary Activities,
  •   Debt and Equity Securities,
  •   Environmental and Disposal Liabilities,
  •   Stewardship Investments,     
  •   Commitments, 
  •   Public-Private Partnerships, and
  •   Funds from Dedicated Collections.

Federal entities should submit to Fiscal Service their contact information for internal representatives who are considered technical experts in the subject matter areas listed above, and will be the point of contact for close collaboration throughout interim analysis and preparation of the FR. Contact information (name, phone number, email address, and subject matter area(s) of expertise) should be submitted to Fiscal Service at financial.reports@fiscal.treasury.gov no later than 21 business days after the end of the third quarter. Fiscal Service will provide the federal entity technical experts, as identified by the federal entity, the Significant Disclosures template, a copy of the final published version of the above listed note(s) from the prior-year FR (Word document), as well as auditor comments on each note (if applicable) received throughout the prior-year FR preparation process. Federal entity technical experts are required to provide feedback on the Significant Disclosures template on items of significance that occurred during the FY that should be considered by Fiscal Service for disclosure in the FR during its analysis and compilation process. With SFFAS No. 57 in effect for FY 2020 reporting, the Significant Disclosure template will include questions about Stewardship Investments. In addition, federal entities are required to provide current-year updates, e.g., changes to existing wording, addition of new material information, etc., to the prior-year notes using Word documents with the Track Changes feature in Microsoft Word. This must also include any changes to the MD&A for Stewardship Investments. Auditor comments received on the above notes listed during the prior-year FR preparation process are provided to the federal entity technical experts to use as a guide for understanding auditor perspectives and expectations during review of the FR. The intention is to use this understanding to resolve in advance any issues for the current FY that can be anticipated based on auditor feedback on prior-year disclosures in the FR. Federal entity participation in this collaboration initiative will be measured on the entity’s year-end scorecards for the current FY. Federal entities should be aware that Fiscal Service will resend the Significant Disclosures template and draft copies of third quarter updates to the above listed notes (Word document) as a follow up within one week of the entities' financial statements due date, and the requirements will be the same as the third quarter collaboration process. Federal entity technical experts must provide feedback on the Significant Disclosures template for items of significance that occurred from third quarter to the fiscal year-end that should be considered by Fiscal Service for disclosure in the FR during its analysis and compilation process. In addition, federal entities are required to provide year-end updates, e.g., changes to existing wording, addition of new material information, etc., to the draft notes Word documents using the Track Changes feature in Microsoft Word. Participation in this collaboration process will also be measured on federal entities’ year-end scorecards.

Section 4705—FR Data Requirements

Significant entities must:

  • Submit audited financial statements in an AFR/PAR in MAX.gov. Please refer to OMB Circular No. A-136 for details.
  • Submit a GTAS ATB. GTAS will crosswalk the ATB data to populate a Balance Sheet, Reclassified SNC, and Reclassified SCNP by reporting entity using the USSGL Reclassified Crosswalk. These reclassified financial statements need to be verified by federal entities in GTAS and used in Note 44: Reclassification Adjustments of AFR Due to FR Compilation in OMB Circular No. A-136. Reference the Reclassified Crosswalks on the USSGL website for additional guidance.
  • Submit an interim and year-end variance analysis in MAX.gov as required in OMB Circular No. A-136 Section IV.2.
  • Provide Fiscal Service with an electronic copy of the interim unaudited financial statements (the third-quarter financial statements), notes, RSI, and OI, if the information is not available on OMB’s MAX federal community website. Notify Fiscal Service of any additional updates to the financial statements as they are made available on MAX.gov website (see subsection 4704.10).
  • Comply with the intra-governmental requirements that can be found in Section 4708.
  • Review (with their auditors) the year-end scorecard to determine if a prior-year journal voucher was processed. If so, then the significant entity should identify the reason for the journal voucher as well as how to prevent the adjustment in the current year.

Contact Fiscal Service to determine the reporting procedures for any adjustments to the GTAS data and AFR/PAR after their publication, which is normally November 15. For contact information, see the GTAS Contacts page.

4705.10—Budget Deficit (Surplus) Reconciliation

Budget Deficit (Surplus) reporting in the FR is based on the published Monthly Treasury Statement (MTS) as of June 30 for third quarter and September 30 for fourth quarter, which is compiled from federal entities’ monthly reports to Treasury’s Central Accounting Reporting System (CARS). Those monthly reports to CARS may include, for example, the Classification Transactions and Accountability (CTA) report, the Statements of Transactions–SF 224, and the Statement of Accountability/Transactions–SF 1219/1220. The MTS, which conforms to the Budget of the U.S. Government, summarizes the financial activities of the federal government and off-budget federal entities.

The Budget Deficit (Surplus) Reconciliation validates the budget deficit (surplus) reported in the FR (on the Statement of Changes in Cash Balance from Budget and Other Activities, and the Reconciliation of Net Operating Cost and Budget Deficit) against entity audited financial statements.

Using the Budget Deficit (Surplus) Reconciliation Template provided by Fiscal Service, entities must identify and explain any inconsistencies at both third quarter and at year-end. The Budget Deficit (Surplus) Reconciliation Template is divided into four sections. These sections leverage reconciliations that entities already perform for net outlays, focus on collecting budget receipts data for all entities, and identify undistributed offsetting receipts data for key contributing entities. Each component of the budget deficit (surplus) is reconciled as shown below: 

Entities can refer to the GTAS website for instructions on how to complete the Budget Deficit (Surplus) Reconciliation Template. Entities must submit this reconciliation 45 business days after third quarter and again at fiscal year-end. All applicable documents are to be transmitted through MAX.gov but may also be transmitted directly to Fiscal Service in accordance with Fiscal Service requests.

4705.20—Federal Trading Partner Notes

Federal trading partners and amounts for each federal line item reported based on the reclassified financial statements will be derived from GTAS ATB data. Amounts identified as federal should be net of intra-departmental eliminations with the following exceptions:  

  • For U.S. Office of Personnel Management only, intra-departmental imputed costs reported with a trading partner code of unknown, and
  • Regular expenditure transfers from Trust Fund accounts and Fiduciary Fund accounts to other general appropriated funds.

Identifying the trading partner enables analysis and elimination of federal activity/balances based on reciprocal categories at the government-wide level. See Appendices 1a and 1b for a complete list of AIDs and FR entities.

All General Fund activity will be reported to the appropriate reclassified financial statement line within RC 30–RC 48 activities. The General Fund activity based on the USSGL and federal/non-federal attributes will be reported to the appropriate reclassified financial statement line within RC 30–RC 48 (see Appendices 2 and 3 for the appropriate reclassification of reclassified financial statement lines) using a federal/non-federal attribute domain value of “G.” See Appendix 11 for more details on transactions with the General Fund.

4705.30—Reclassification of Significant Entities’ Financial Statements

Significant entities must submit GTAS ATB data. GTAS will then populate the Balance Sheet and two reclassified financial statements based on the USSGL crosswalks. The USSGL crosswalks for the Balance Sheet, SNC, and SOCNP can be found in USSGL guidance (Section VI-Crosswalks to Reclassified Statements). These reports can be accessed in GTAS and are titled “Reclassified Financial Statements – Balance Sheet, Reclassified SNC, and Reclassified SOCNP.” Significant entities must use these GTAS reports to complete Note 44: Reclassification Adjustments of AFR Due to FR Compilation in OMB Circular No. A-136.

Significant entities report the line items on their financial statements based on what is most material and useful to them. These line items may not match line items in the reclassified financial statements for several reasons. For example, the reclassified financial statement line items may not apply to the federal entity, the amounts could be immaterial at the entity level, or the entity may find it useful to include more detail than the reclassified financial statement lines. Federal entities must submit ATB data to GTAS for the reclassified financial statement lines, regardless of materiality.

4705.30a—Custodial Activity

SFFAS No. 7, paragraph 353, states:

Disposition of revenue to other entities: custodial transfers—Revenue, primarily non-exchange revenue, may be collected by an entity acting on behalf of the General Fund or another entity within the government on whose behalf it was collected. The collecting entity accounts for the disposition of revenue as part of its custodial activity. These custodial transfers, by definition, do not affect the collecting entity’s net cost of operations or operating results, nor are they part of the reconciliation between its obligations and net cost of operations. (The receiving entity recognizes the revenue as non-exchange or exchange revenue depending on its nature, according to the applicable revenue standards.)

For exchange revenue with virtually no cost, see SFFAS No. 7, paragraph 140. The custodial revenue is reported by the collecting entity on the Statement of Custodial Activity or on the Custodial Activity Note.

However, for exchange revenue collected for others with related cost incurred, federal entities should follow the guidance from SFFAS No. 7, paragraph 137, which states:

As a general rule, exchange revenue transferred to others must be offset against the collecting entity’s gross cost to determine its net cost of operations. Exchange revenue reduces the net cost of operations incurred by the entity in producing outputs, regardless of whether the entity keeps the exchange revenue for its own use or transfers it to another operating entity or the General Fund. Likewise, exchange revenue reduces the net cost of the entity’s operations to the taxpayer regardless of its disposition. Therefore, all exchange revenue related to the cost of operations must be deducted from gross cost to determine the net cost of operations for the entity.

It is noted that the General Fund does not engage in Buy/Sell intra-governmental transactions or exchange activity with associated costs. In exceptional circumstances, the General Fund will have exchange revenue without associated costs; these circumstances must be evaluated by Fiscal Service on a case by case basis.

Furthermore, SFFAS No. 7, paragraph 138, states:

Any exchange revenue that is transferred to others, however, does not affect the collecting entity’s net position. Therefore, as required by the standards for other financing sources, such exchange revenue is recognized as a transfer-out in calculating the entity’s operating results.

At the government-wide level, these collections are recognized as revenue.

Significant entities that report a Statement or Note on Custodial Activity in their comparative, audited consolidated, department-level financial statements should show an adjustment of the exchange revenue without associated costs and non-exchange revenue from the Statement or Note on the Custodial Activity to the SOCNP on Note 44: Reclassification Adjustments of AFR Due to FR Compilation in OMB Circular No. A-136. From the Sources of Collections section of the Custodial Statement or Note (with the exception of customs duties, excise taxes, and taxes collected by the Department of the Treasury, the Department of Labor, and the Department of Homeland Security), reclassify all non-exchange revenue lines to “Other taxes and receipts” and exchange lines to “Miscellaneous earned revenue.” From the Disposition of Collections section, reclassify all federal lines to “Other Budgetary Financing Sources” and non-federal lines to “Other taxes and receipts.”

Federal entities must report the custodial revenue as non-federal “N” at the time of collection from the public (that is, the Sources of Collection section). The disposition of the custodial revenue to other federal entities must be reported as federal “F” in the Reclassified SNC or SOCNP when reporting in GTAS. Any federal entity receiving custodial revenue from the collecting entity must report this revenue as federal “F” in its Reclassified SNC or SOCNP when reporting in GTAS. If the collecting entity retains a portion of the custodial revenue, the entity must report this revenue as non-federal, “N” at the time of collection from the public. If the revenue is transferred between intra-departmental funds, those transactions should be reported as federal “F” in its Reclassified SNC or SOCNP when reporting in GTAS and must use its own trading partner AID. The federal entity must ensure the amounts reported with its own trading partner AID eliminate appropriately.

There may be situations in which custodial revenue collected in a TAS of one federal entity and, subsequently, transferred to another TAS (other than General Fund), is identified as inappropriate by Treasury and OMB. Additionally, there may be situations in which there is not currently a TAS for the federal custodial entity to record the custodial collection and subsequent distribution. For both situations, Fiscal Service has worked with OMB to assign a series (F3600-F3699) of clearing accounts to coordinate the reporting of custodial activity between the two federal entities (neither of which are the General Fund). For additional information on the requirements for establishing one of these accounts, please email GovernmentwideIGT@fiscal.treasury.gov.

If federal entities have collections that do not meet Statement or Note on Custodial Activity reporting requirements, they should refer to the General Fund Receipt Account Guide.

4705.30b—Funds From Dedicated Collections

Funds from dedicated collections are financed by specifically identified revenues, often supplemented by other financing sources, which remain available over time. These specifically identified revenues and other financing sources are required by statute to be used for designated activities, benefits, or purposes and must be accounted for separately from the government’s general revenues in accordance with SFFAS No. 27 as amended by SFFAS No. 43. SFFAS No. 43 modified the definition of these funds by clarifying that at least one source of fund, external to the federal government, must exist for a fund to qualify as a fund from dedicated collections. SFFAS No. 43 also added an explicit exclusion for any fund established to account for pensions, other retirement benefits, other post-employment, or other benefits provided for federal employees (civilian and military).

At the government-wide level, the U.S. government's Balance Sheet shows separately the portion of the net position attributable to funds from dedicated collections as combined and labels those lines accordingly. Combined presentation does not eliminate intra-governmental balances or transactions with an entity. Intra-governmental transactions such as transfers amongst funds should not be eliminated or removed from the combined presentation. Note that intra-governmental activity that occurs within the same main account code should be eliminated for combined purposes. The standard further requires the disclosure of condensed information on assets, liabilities, and net cost for all funds from dedicated collections. Fiscal Service is requesting that the disclosure be presented as combined amounts. If a federal entity decides to present the Balance Sheet net position as consolidated, it must disclose a crosswalk from the consolidated to combined net position amounts in the Funds from Dedicated Collection Note. The crosswalk will be concurrence to process a journal voucher at the government-wide level, converting the Balance Sheet net position from consolidated to combined.

In addition, a crosswalk will need to be included to identify the difference of revenue presented on an entity’s SCNP to the government-wide SOCNP. Please refer to Note 44 of OMB Circular No. A-136 for more details.

Significant entities must ensure that funds from dedicated collections are denoted on the SMAF in GTAS as an “E” for the Reporting Type Code. This will crosswalk the funds from dedicated collections amounts and activity to the applicable reclassified financial statement line items. For additional guidance, see OMB Circular No. A-136.

4705.30c—Criminal Debt

Criminal debt primarily consists of fines and restitution that result from a wide range of criminal activities, including domestic and international terrorism, drug trafficking, firearms activities, and white-collar fraud. When an individual is sentenced in a federal criminal case, the judge may order the defendant to pay certain financial obligations, which may include a case assessment, fine, restitution, penalty, bail bond forfeiture, or interest. The Department of Justice’s Executive Office for U.S. Attorneys is responsible for establishing policies and procedures for the collection of criminal monetary penalties. The U.S. Attorneys are responsible for the enforcement of judgments, fines, penalties, and forfeitures imposed in their respective districts. There are 93 U.S. Attorneys stationed throughout the 50 states, Puerto Rico, the Virgin Islands, Guam, and the Northern Mariana Islands. The U.S. Attorneys publish the Annual Statistical Report that contains statistical tables displaying both national and district caseload data, covering the many priorities of the U.S. Attorneys in both criminal prosecution and civil litigation. The data supporting the Annual Statistical Report is obtained from the Department of Justice (Justice) Consolidated Debt Collection System (CDCS). The CDCS is the system of record for debts being collected by Justice on behalf of others, including federal entities. The system is used by the U.S. Attorneys' Offices, Justice’s other litigating divisions, and contracted Private Counsel Offices to monitor and track delinquent civil and criminal debts owed to the federal government. The funds collected in federal restitution are disbursed back to the appropriate federal entities, while funds collected in bond forfeitures, fines and assessments are deposited into the Crime Victims Fund. Funds collected from penalties and certain costs are deposited in the General Fund of the U.S. Government. The U.S. Courts assist Justice with the receipt and distribution of financial obligations ordered in a criminal judgment and serve as a conduit between the defendant and Justice. The majority of payments made to satisfy criminal restitution are received at the Clerk of Court offices. The Clerk of Court offices have the payee details from the criminal judgment to ensure proper disbursement of payments.

Non-exchange revenues include income taxes, excise taxes, employment taxes, duties, fines, penalties, and other inflows of resources arising from the government’s power to demand payments from the public. Non-exchange revenue should be recognized when a specifically identifiable, legally enforceable claim to resources arises, to the extent that collection is probable (more likely than not) and the amount is reasonably estimable (SFFAS No. 7, par. 48). For accounts receivable resulting from non-exchange transactions, recognition is based on the completion of the assessment process that establishes an identifiable, legally enforceable claim to cash or other assets (SFFAS No. 7, par. 53). Assessments recognized as accounts receivable include court actions determining an assessment (SFFAS No. 7, par. 54). Federal accounting standards require that an allowance for uncollectible amounts be established to reduce the gross amount of receivables to its net realizable value (SFFAS No. 1, par. 45).

Public Access to Court Electronic Records (PACER) is an electronic public access service that allows registered users to obtain case and docket information online from federal appellate, district, and bankruptcy courts. The Judgment in a Criminal Case form issued by a court is a public record filed with the Clerk of Courts. The criminal judgment form and related case documents can be obtained via PACER. The Judgment in a Criminal Case form includes a schedule for Criminal Monetary Penalties, which details if any assessments, fines, or restitution have been established in the final judgment in a criminal case and lists the payees and amount of restitution ordered for each payee. This schedule also indicates if the fine or restitution are subject to interest. The Judgment in a Criminal Case form also includes the Schedule of Payments, which lists the specific details as to when payments are to commence and the frequency of when payments are due. When a federal entity is listed as a payee in the Judgment in a Criminal Case form, the legally enforceable claim to cash or other assets is established.

Significant entities and other entities that are owed restitution as the result of a judgment in a criminal case are required to report in Note 6: Accounts Receivable, Net in OMB Circular No. A-136.

4705.30d—Social Insurance

The Statements of Social Insurance (SOSI) and the Statement of Changes in Social Insurance Amounts (SCSIA) are required by SFFAS Nos. 17, 25, 26, 28, and 37 to be presented as basic financial statements. The Social Insurance reporting agencies (SIRAs) are the Social Security Administration (SSA), the Department of Health and Human Services (HHS), the Railroad Retirement Board (RRB), and the Department of Labor (DOL).

Most of the social insurance information pertaining to Social Security and Medicare can be obtained from SSA (the 2020 Annual Report of the Board of Trustees of the Federal Old-Age and Survivors Insurance and Federal Disability Insurance Trust Funds) and from HHS (the 2020 Annual Report of the Boards of the Trustees of the Federal Hospital Insurance and the Federal Supplementary Medical Insurance Trust Funds, and the CMS (Centers for Medicare and Medicaid Services) Actuary Workbook). The remaining data for social insurance from SSA and HHS will come from their AFR/PAR. It is noted the social insurance information from RRB and DOL will come directly from their AFR/PAR. RRB, however, will provide to Fiscal Service a spreadsheet with the amounts of its current year SCSIA for data entry purposes. For additional guidance, see OMB Circular No. A-136.

4705.30e—Fiduciary Activities

In a fiduciary activity, the government collects or receives and subsequently manages, protects, accounts for, invests, "and/or" disposes of cash or other assets in which non-federal individuals or federal entities have an ownership interest that the government must uphold. Non-federal individuals and federal entities must have an ownership interest in the cash or other assets held by the government under provision of loan, regulation, or other fiduciary arrangement. The ownership interest must be enforceable against the government, and judicial remedies must be available for the breach of the government’s fiduciary obligation. Federal entities should account for this fiduciary activity, which includes the collection of cash or other assets and their distribution to the non-federal owners or their beneficiaries, in accordance with SFFAS No. 31. In accordance with the standard, there is relatively similar government activity that is specifically excluded from the SFFAS No. 31 reporting requirements, such as payroll withholdings and garnishments; unearned revenue; and seized property.

The standard requires that the government’s fiduciary activities and a description thereof be included as a note disclosure. In addition, the government must disclose that the fiduciary assets are not assets of the government and are, therefore, not recognized on the U.S. Government Balance Sheet. However, at the government-wide level, the U.S. Government Balance Sheet recognizes a liability for fiduciary Fund Balance with Treasury and a liability for fiduciary investments in U.S. Treasury securities that are included in the federal entities’ fiduciary assets. Federal entities must make sure to report the TASs that are fiduciary to Fiscal Service to ensure the data crosswalks properly to the AFRs/PARs.

However, both significant entities and other entities with fiduciary activity must enter the federal entity fiduciary activity note disclosure information in Note 38: Fiduciary Activities in OMB Circular No. A-136.

Significant entities must ensure that fiduciary activities are denoted on the SMAF in GTAS as a “F” for Reporting Type Code.

Note: The reporting requirements related to fiduciary activities, as required by SFFAS No. 31, are distinct and unrelated to the reporting and other requirements related to the “fiduciary” category of intra-governmental transactions as stated in subsections 4708.20 and 4708.30a.

4705.30f—Reporting of Government Account Series (GAS) Investments with Fiscal Service Purchased by Federal Entities Using Fiduciary or Non-fiduciary Funds

Treasury GAS securities purchased using a non-fiduciary fund are normally classified as intra-governmental. The investments in GAS securities by non-fiduciary funds and the associated USSGL accounts should be reported with a federal/non-federal attribute domain value of “F” with a corresponding federal trading partner of 020 for Treasury.

The purchase of Treasury GAS securities using a fiduciary fund is not classified as intra-governmental. The investments in GAS securities by a fiduciary fund and the associated USSGL accounts should be reported with a federal/non-federal attribute domain value of "F” with a corresponding federal trading partner of 020 for Treasury for budgetary reporting only. The balance will be excluded from the Balance Sheet when consolidating the FR if reported by an account with Reporting Type Code attribute domain value “F” (fiduciary).

Note: Treasury will still report the liability as debt held by the public with federal/non-federal attribute domain value “N” to allow for appropriate Balance Sheet presentation on the FR.

4705.30g—Department Code Reporting for General Fund Activities

Federal entities that record activities with the General Fund must properly record the activity at the government-wide level to assist with the preparation of the FR. Refer to USSGL guidance (Section VI-Crosswalks to Reclassified Statements) for a description of each reclassified FR line, and Appendices 2 and 3 for a listing of reclassified FR line reciprocal category designations and the financial statement to which they relate. Please refer to Appendix 11 for full General Fund reporting guidance.

Federal entities should contact Fiscal Service, via email at GovernmentwideIGT@fiscal.treasury.gov, if they are unsure about what the correct trading partner assignment is for a particular transaction.

4705.30h—Non-reciprocating Activities

Z (Intra-governmental)—This is an attribute domain value of a USSGL account balance that results from transactions that are intra-governmental in nature, but no reciprocal balances will be reported by any other federal entity. The attribute is limited to Reciprocal Category 29.

An example of a non-reciprocating activity is as follows:

  • Liabilities temporarily recorded to clearing accounts related to intra-governmental activity.

4705.40—Special Basis of Accounting

SFFAS No. 34, The Hierarchy of Generally Accepted Accounting Principles, establishes what constitutes GAAP for federal reporting entities. SFFAS No. 34 recognizes that some federal component reporting entities prepare and publish financial statements (pursuant to the accounting and reporting standards issued by the FASB), and provides that such financial statements prepared in conformity with accounting standards issued by the FASB also may be regarded as in conformity with GAAP. Per SFFAS No. 47, Reporting Entity, consolidation entities (that is, the consolidated government-wide reporting entity or a consolidated component reporting entity) may consolidate component or sub-component reporting entity financial statements prepared in accordance with FASB GAAP without conversion for any differences in accounting policies among the organizations. As a result, entities reporting in conformity with FASB GAAP, consistent with SFFAS 34, may also report their data to GTAS in conformity with FASB GAAP.

Significant entities that are FASB reporters need to also report the information in OMB Circular No. A-136, Section II.3.8.44 -Note 44: Reclassification of Balance Sheet, SNC, and SCNP for FR Compilation Process (Note 44). Such information may be reported by the significant reporting entity in (i) its annual financial report within a note to the financial statements, (ii) a limited use audited financial statements that includes the Note 44, or (iii) an audited Note 44 (an audit of a special element). Significant entities that are FASB reporters with a calendar year-end should provide reclassification information to Fiscal Service with the audit assurance limited to the line items or note disclosures identified by Fiscal Service, as discussed below. The FASB reporting entities will also provide Treasury the associated crosswalk used to prepare Note 44. Please see the OMB Circular No. A-136 for complete details.

(1) Significant entities that are currently FASB reporters are:

  • Federal Deposit Insurance Corporation,
  • National Credit Union Administration,
  • NRRIT,
  • Pension Benefit Guaranty Corporation,
  • Smithsonian Institution,
  • Tennessee Valley Authority,
  • U.S. Postal Service, and
  • Farm Credit System Insurance Corporation.

Significant entities with a year-end other than September 30 (i.e. calendar year-end) are subject to all requirements of this TFM chapter. Significant entities with a calendar year-end will report their September 30 account balances in their GTAS ATB submission in accordance with the GTAS Reporting Window Schedule. This set of data, as of September 30, will be used to populate the reclassified financial statement lines through the USSGL crosswalk. These entities are required to have audit assurance on line items or note disclosures that contribute to the top 95% of the total FR line item data. These entities will receive a quarterly report from Treasury, so they know which lines are required to have audit assurance as of September 30 each year. Provide Fiscal Service a copy of the independent audit report that includes the results of the audit performed on the material line items and notes disclosures identified by Fiscal Service.

(2) Significant entities with a calendar year-end:

  • Farm Credit System Insurance Corporation,
  • Federal Deposit Insurance Corporation, and
  • National Credit Union Administration.

4705.50—Parent/Child Reporting

The parent entity (transferor of the appropriation) must report all activity of the child in its financial statements, whether material to the child entity (recipient of the transfer) or not, unless one of the two exceptions (detailed below) applies. The parent entity is the trading partner entity for activity involving these TAS. For more detail on how to report trading partner information, please refer to Appendices 1a and 1b. 

The two exceptions to the requirement for parent/child reporting (from OMB Circular No. A-136, revised) are:

  1. The parent is the Executive Office of the President.
  2. Funds transferred from the Judiciary to the Department of Justice’s (DOJ) U.S. Marshals Service for court security.

In these cases, the receiving entity (child) is responsible for reporting all proprietary activity in its financial statements and is the trading partner entity. Please refer to Appendices 1a and 1b for details on reporting trading partner information.

GTAS requires the parent entity and the child entity to agree on which federal entity will report the TAS in the bulk file submission.

4705.60—Reciprocal Categories

A Reciprocal Category is comprised of a set of reclassified financial statement line items that are the reciprocal of each other (for example, accounts payable/accounts receivable). These categories assist in the elimination of federal activity at the government-wide level to prepare the FR. Additionally, these reciprocal categories facilitate the reconciliation of activities between federal entities. Please see Appendix 2 for a complete list of reciprocal categories and the financial statements to which they relate.

Note: General Fund activities must report via GTAS ATB to be crosswalked to a reclassified financial statement line with a RC 30–48 designation for identifying General Fund activity at the government-wide level.

4705.70—Treaties and Other International Agreements

Treaties and other international agreements may create liabilities and contingencies requiring recognition or disclosure in the financial statements. As such, all federal entities should consider treaties and other international agreements in the analysis and preparation of the entities' annual financial statements.

Treaties and other international agreements are written agreements between the U.S. and other sovereign states, or between the U.S. and international organizations, governed by international law. The subjects of treaties span the whole spectrum of international relations: peace, trade, defense, territorial boundaries, human rights, law enforcement, environmental matters, and many others. The Department of State (State) developed and continues to manage the Circular 175 Procedure (C-175 Procedure), which outlines the approval process for the negotiation and conclusion of international agreements to which the U.S. will become a party. State publishes a list of treaties and other international agreements of the U.S. in force as of January 1st each year in a document titled, Treaties in ForceNot all treaties and other international agreements are subject to the C-175 Procedure. Below are the exceptions:

  • Trade agreements [CFR 181.4(g)], and
  • Many routine agency-level implementing arrangements [22 CFR 181.4(a) and 22 CFR 181.3(c)].

As discussed in SFFAS No. 5, “A liability for federal accounting purposes is a probable future outflow or other sacrifice of resources as a result of past transactions or events.” SFFAS No. 5 also states that “The probability of a future outflow or other sacrifice of resources is assessed on the basis of current facts and circumstances. These current facts and circumstances include the law that provides general authority for federal entity operations and specific budget authority to fund programs. If budget authority has not yet been provided, a future outflow or other sacrifice of resources might still meet the probability test if (1) it directly relates to ongoing entity operations and (2) it is the type for which budget authority is routinely provided. Therefore, the definition applies both to liabilities covered by budgetary resources and to liabilities not covered by budgetary resources.”

Per State’s C-175 Procedure, federal entities negotiating and concluding treaties and other international agreements on behalf of the U.S. Government are required to indicate whether a proposed treaty or other international agreement embodies a commitment to furnish funds, goods, services, or other measurable future financial obligations beyond or in addition to those authorized in an approved budget; and if so, what arrangements are being planned or carried out by the federal entity concerning consultation with OMB for such commitment. State will not authorize such commitments without confirmation that the relevant budget approved by the President requests or provides funds adequate to fulfill the proposed commitment, or that the President has decided to seek the required funds. All provisions of the C-175 Procedure apply whether a proposed treaty or other international agreement is to be concluded in the name of the U.S. Government, or in the name of a particular federal entity of the U.S. Government.

For financial reporting purposes, all treaties and other international agreements may be understood as falling into three broad categories:

  1. No present or contingent obligation to provide goods, services, or financial support (no recognition or disclosure),
  2. Present obligation to provide goods, services, or financial support (recognition), or
  3. Contingent obligation to provide goods, services, or financial support (may require recognition or disclosure).

No Present or Contingent Obligation to Provide Goods, Services, or Financial Support (no recognition or disclosure)

Treaties and other international agreements under the first category do not result in a liability or contingency when entered into force. Instead, these treaties or other international agreements may establish frameworks that govern cooperative activities, such as aviation safety with other countries, but leave to the discretion of the parties whether to engage in any such activities. In other cases, the agreements may contemplate specific cooperative activities, but create no present or contingent obligations to engage in them. Cooperative activities relevant to these treaties and other international agreements often involve actions that federal entities undertake as part of their regular operations, funded by their regular budgets.

Present Obligation to Provide Goods, Services, or Financial Support (recognition)

Treaties and other international agreements falling in the second category involve a present obligation, and therefore result in liability recognition. Such present obligation may relate to the U.S. Government providing financial and in-kind support, including assessed contributions, voluntary contributions, grants, and other assistance to international organizations in which it participates as a member. Examples of such agreements include:

  • Agreements establishing international organizations, under which the U.S. Government undertakes obligations to pay assessed dues to the organization,
  • Grant agreements under which the U.S. Government provides foreign assistance funds to other countries, and
  • Claims settlement agreements under which the U.S. Government agrees to pay specific sums of money to settle claims.

Such agreements may not be entered without specific statutory authority to undertake the obligation to spend money. Liabilities arising from such agreements should be recognized for any unpaid amounts due as of the reporting date. The liabilities include amounts due from the federal entity to pay for benefits, goods, or services provided under terms of the agreements, as of the entity’s reporting date, whether such amounts have been reported to the entity. These liabilities may either be fully funded or established against future funding.

Contingent Obligation to Provide Goods, Services, or Financial Support (may require recognition or disclosure)

The last category encompasses treaties or other international agreements which result in contingencies that may require recognition or disclosure in the financial statements. Such contingencies may stem from commitments in a treaty or other international agreement to provide goods, services, or financial support when a future event occurs, or from litigation, claims, or assessments forged by other parties to the agreement. In such instances, conditions, situations, or circumstances exist involving uncertainty as to possible gain or loss to an entity that will ultimately be resolved when one or more future events occur or fail to occur. In accordance with SFFAS No. 5, a contingent liability should be recognized on the face of the basic financial statements when a past event or exchange transaction has occurred and a future outflow or other sacrifice of resources is probable and measurable. If any of the conditions for liability recognition are not met, and there is at least a reasonable possibility that a loss or an additional loss may have been incurred, a contingent liability should be disclosed in the notes regarded as an integral part of the basic financial statements.

Disclosure should include the nature of the contingency and an estimate of the possible liability, an estimate of the range of possible liability, or a statement that such an estimate cannot be made. For circumstances where the recognition or disclosure of a contingent liability relates to litigation, claims, or assessments resulting from the U.S. Government’s involvement in a treaty or other international agreement, federal entities should summarize the financial treatment of such contingencies (recognition or disclosure) relative to the financial statements in the annual legal letter process. For a summary of the proper financial treatment of contingent liabilities related to litigation, claims, and assessments, refer to subsection 4707.10—Legal Letter Reporting Requirements.

Federal entity management must determine whether the entity has treaties and other international agreements it is responsible for reporting. If the federal entity has treaties and other international agreements it is responsible for reporting, entity management must:

  • Develop and implement effective internal controls to reasonably assure (1) the proper financial reporting of treaties and other international agreements, including a review of potential contingent liabilities; and (2) the establishment of related liabilities and note disclosures for both liabilities covered and not covered by budgetary resources.
  • For each treaty and other international agreement, determine the appropriate category (i.e., no present or contingent obligation to provide goods, services, or financial support; present obligation to provide goods, services, or financial support; or contingent obligation to provide goods, services, or financial support).
  • Review, with General Counsel (at least annually), the entity’s treaties and other international agreements relative to appropriate FASAB or FASB standards to identify, monitor, and report any related commitments and contingencies. In alignment with guidance defined in SFFAS No. 5, as amended, recognition or disclosure of a contingent liability is based on the likelihood and measurability of a future outflow or other sacrifice of resources.

4706—Management Representation Letter (MRL)

In accordance with OMB Circular No. A-136, Section V.5., the written representations from the federal entities’ management and accompanying Summary of Uncorrected Misstatements (SUM) are required for the audits of federal entity financial statements used to compile the FR. Significant entities with a year-end other than September 30 need to provide a MRL to Fiscal Service (see Figure 2 for due dates). Significant entities that are FASAB and FASB reporters that report on the fiscal or calendar year-end are required to provide the representations shown in the current OMB Audit Bulletin, Section 8.5 and Appendix E. Federal entities should attach in Excel format a comprehensive SUM that includes uncorrected misstatements from the financial statement audit. Please refer to 4706.20 (Summary of Uncorrected Misstatements Process), guidance in OMB Circular No. A-136, Section V.5, the current OMB Audit Bulletin, Section 8 (Written Representations from Management), Appendix E (Illustrative Written Representations from Management for the Financial Statements), and the Financial Audit Manual Volume 2, Section 1001.

4706.10—Other Required Information for Management Representation Letters

Significant entity CFOs also must provide Fiscal Service information regarding any subsequent changes to their MRL’s and published financial statements. The subsequent events email should indicate “no changes”, or “changes” due to the written representation from management or subsequent events affecting the federal entity financial statements. Subsequent event information is based on the federal entity’s materiality threshold. Send this information via email (contacts listed at the end of this chapter) to Fiscal Service, Treasury (Main), OMB, and GAO (see Figure 2 for due dates and OMB Circular No. A-136, Section V.5 for wording requirements). 

4706.20—Summary of Uncorrected Misstatements (SUM) Process

Significant entities must include a SUM as a part of their financial statement MRL (as stated in Section 4706). Significant entities with a year-end other than September 30 do not have to provide a SUM. The SUM is for federal entities’ current-year Balance Sheet, SNC/Income Statement, SCNP, Statement of Social Insurance, and Statement of Changes in Social Insurance Amounts (if applicable). If there are no uncorrected misstatements, a representation to this effect is required in the MRL.

Federal entities are required to provide the adjusting entries to correct the misstatements. A summary of uncorrected misstatements and adjusting entries must be submitted in the standardized Excel format as shown in the Financial Audit Manual, Section 595C, and should contain the following:

  • The effect of the current-year’s uncorrected misstatements and the carry-forward effect of the prior-year’s uncorrected misstatements.
  • USSGL account number and account description.
  • Federal (F), General Fund (G), Non-reciprocating (Z), or Non-Federal (N) attribute for each USSGL account affected.
  • A reference to an adjustment number or documentation reference.
  • An indication as to whether management has agreed to record the adjustment in its financial statements.
  • A statement as to whether the uncorrected misstatement is factual, judgmental, or projected.
  • A description of the adjustment.
  • The amount of the debit or credit.
  • The line items affected in the consolidated financial statements. 
  • Uncorrected misstatements identified in the audit of the federal entity’s financial statements.

Please refer to the example below for reporting the adjusting entries for the summary of uncorrected misstatements to Fiscal Service.

For additional guidance, see the current OMB Audit Bulletin, Section 8 (Written Representations from Management) and Appendix E (Illustrative Written Representations from Management for the Financial Statements), and OMB Circular No. A-136, revised, on the OMB website and GAO’s Financial Audit Manual, Section 595C, on the GAO website.

4707—Legal Representation Letter Process

4707.10—Legal Letter Reporting Requirements

Significant entities' General Counsel must prepare an interim and final legal representation letter that describes and evaluates pending or threatened litigation, claims, and assessments with which the legal counsel has been engaged and has devoted substantial attention on behalf of the entity in the form of legal consultation or representation. When preparing the legal representation letter, significant entity's General Counsel must also consider unasserted claims and assessments that management considers to be probable of assertion and that, if asserted, would have at least a reasonable possibility of an unfavorable outcome.

All pending and threatened litigation, as well as unasserted claims above a materiality level agreed upon by significant entity management and its auditor must be reported using the applicable form found on DOJ’s website. When determining the materiality level for the legal representation letter, significant entities and their auditors should set the level sufficiently low so that the cases not included in the legal letter would not be material to the financial statements taken as a whole when aggregated with other items as described in GAO’s Financial Audit Manual (FAM), Section 1002.18. In aggregating cases, the significant entity and the auditor may use two levels of aggregation as discussed in FAM, Section 1002.19. First, similar cases are aggregated, treated as a group, and compared with the individual materiality level. Second, cases not included in the legal letter individually or as part of a group of similar cases are aggregated.

The legal representation letter must categorize cases, including cases to be paid from the Judgment Fund, as having a probable, reasonably possible, remote, or unable to determine chance of a negative outcome for the significant entity, consistent with the American Bar Association’s Statement of Policy Regarding Lawyer’s Responses to Auditor’s Requests for Information (December 1975). When preparing the legal representation letters, General Counsel should also reference guidance found in OMB Audit Bulletin.

For circumstances where litigation, claims, and assessments involve lead representation by outside counsel, e.g., DOJ, significant entity management, in conjunction with its General Counsel, must consult the lead counsel when assessing the likelihood of loss and estimated amount or range of potential loss for cases included in the significant entities’ legal representation letters. It is noted that DOJ prepares a government-wide legal representation letter based on its review of the litigation, claims, and assessments reported by significant entities that are material to the FR. Fiscal Service performs a comparison of the “Pending or Threatened Litigation” and “Unasserted Claims and Assessments” forms included in DOJ’s government-wide legal representation letter to the corresponding forms and Management Schedules included in the legal letter packages submitted by significant entities. If Fiscal Service identifies inconsistencies between DOJ’s and the entities’ assessments of the likelihoods of loss or estimated amounts or ranges of potential loss for these cases, Fiscal Service will contact the significant entity that reported the case to coordinate efforts between the entity and DOJ to resolve the inconsistencies.

In cases that have more than one entity impacted,entities are encouraged to communicate with each other on shared cases to ensure appropriate reporting. Responsibility for the case must be allocated among entities such that 100% of the contingency is accounted for.

Using the Management Schedule template found on the GTAS website, significant entity management must prepare an interim and final “Management’s Schedule of Information Contained in Legal Letter Responses for Financial Reporting Purposes” (Management Schedule) that summarizes the contingencies included in the legal representation letter prepared by General Counsel and documents how the information was used in preparing the entity’s financial statements. The following elements on the Management Schedule must agree with General Counsel’s assessments from each supporting legal representation letter form, or in unusual circumstances where they do not agree, an explanation must be provided on the face of the Management Schedule template:

In addition, significant entity management must indicate the financial treatment (accrual or disclosure) of each contingency on the Management Schedule in relation to the preparation of the entity’s financial statements. Contingent liabilities related to pending or threatened litigation and unasserted claims must be recognized and disclosed in accordance with guidance defined in SFFAS No. 5, Accounting for Liabilities of the Federal Government, as amended, which is summarized in the below table.

*The financial reporting treatment for cases where the likelihood of future outflow or other sacrifice of resources is assessed as “unable to determine” should be consistent with the disclosure requirements for reasonably possible cases.

When evaluating the likelihood of loss for contingent liabilities, significant entities should avoid excessive and misuse of the “unable to determine” assessment. This likelihood should only be used to categorize cases for which the General Counsel is unable to express an opinion due to inherent uncertainties. The financial reporting treatment for cases assessed as “unable to determine” should be consistent with the disclosure requirements for reasonably possible cases. Fiscal Service will require significant entities with a high percentage use of the “unable to determine” assessment to provide written documentation of their internal processes for using this assessment when evaluating legal cases.

When evaluating the estimated amounts or ranges of potential loss for litigation, claims, and assessments, significant entities that use the claim amount as an estimated loss should ensure that analysis has been performed that supports the determination that the claim amount is the best estimate of loss. Significant entities are encouraged to review guidance defined in SFFAS No. 5, paragraphs 38-41, as well as the American Bar Association’s Statement of Policy Regarding Lawyer’s Responses to Auditor’s Requests for Information (December 1975).

Significant entity Inspector Generals (IGs) must submit an interim and final legal representation letter prepared and signed by General Counsel, as well as an interim and final Management Schedule prepared by management to Fiscal Service, DOJ, and GAO (see Figure 2 for due dates). The interim Management Schedule should represent information as of June 30 and the final legal representation letter must include all existing, pending, or threatened litigation and unasserted claims as of September 30. Only Management Schedules as of these dates should be submitted in order to remain consistent with the reporting period. To limit the number of emails required to complete the legal representation letter package submission, legal letter files must be combined into a single file PDF, (i.e., avoid including a separate PDF file for each case), and submitted via email; zipped files will not be accepted. Management Schedules must be submitted in Excel format using the template provided by Fiscal Service. If the significant entity IG does not use the template provided by Fiscal Service, then the significant entity management must provide the additional details required to support the compilation of the consolidated financial report by preparing the template provided by Fiscal Service for each legal case in Excel format. Fiscal Service will accept this in Excel format as a separate submission, with the same due date as the previously mentioned legal representation letter package. Significant entities must provide contact information for entity representatives who are available to assist Fiscal Service with inquiries related to legal representation letter package submissions. Since multiple areas are involved in the preparation of the legal representation letter package (significant entity management, General Counsel, and IGs), please provide contact information for each area, or indicate that the contact(s) provided serves as sufficient representation for all areas.

The Export-Import Bank of the U.S., Smithsonian Institution, National Railroad Retirement Investment Trust, and calendar year-end federal entities (Farm Credit System Insurance Corporation, Federal Deposit Insurance Corporation, and National Credit Union Administration) are not required to submit an interim legal representation letter and Management Schedule. These significant entity IGs, or significant entity management where applicable, are only required to submit a final legal representation letter and Management Schedule.

To ensure accurate and complete reporting and disclosures of contingent liabilities in the FR, Fiscal Service will review significant entities’ legal representation letter and Management Schedule submissions to confirm contingencies detailed in the legal representation letter have been appropriately summarized on the Management Schedule, and reported and disclosed in the entity’s financial statements in accordance with requirements in SFFAS No. 5, as amended. Significant entities must provide explanations for inconsistencies between the legal representation letter, Management Schedule, and the reporting of contingent liabilities in the financial statements on the face of the Management Schedule. Fiscal Service will follow up on any discrepancies identified in its analysis that have not been explained or justified by the significant entity.

4707.20—Other Required Information for Legal Representation Letters

Significant entity IGs, or significant entity management for certain federal entities, must provide GAO, DOJ, and Fiscal Service information relating to subsequent events that resulted in a change in the likelihood of loss or the estimated amount or range of potential loss, or both, from the effective date of the final Legal Representation Letter (September 30) through February 26, 2021. All significant entity IGs, or significant entity management for certain federal entities, must submit details of the subsequent events via email to GAO, DOJ, and Fiscal Service (Please see Figure 2 for all Legal Representation Letter due dates).

Subsequent event information is based on the significant entity’s materiality threshold. For additional guidance, see OMB Audit Bulletin, and OMB Circular No. A-136, revised, on the OMB website.

Section 4708—Intra-governmental Quarterly and Year-end Requirements

4708.10—Intra-governmental Transactions/Balances

Intra-governmental transactions result from business activities conducted between two federal government entities, called trading partners. Accounting differences occur in government-wide financial reporting when trading partners record differing amounts for transactions that should eliminate or net to zero. All differences should be resolved by year-end. Trading partners must reconcile and resolve these differences on a periodic basis with their trading partners. The Intra-governmental Transaction (IGT) Guide (Appendix 5) contains the business rules and processes to properly record, report, and reconcile intra-governmental transactions, including the processes for dispute resolution.

Note: The Federal Reserve System, which includes the Board of Governors, is not considered a consolidated entity in government-wide reporting entity under federal accounting standards (please note the Board of Governors is considered federal for tax purposes, however, for government-wide reporting, they are considered non-federal). Therefore, payments made to or collections received from the Federal Reserve System would be reported in the financial statements of the federal government and its component reporting entities. All activity with the Board of Governors of the Federal Reserve System must be reported as non-federal “N” activity.

Federal Executive Boards are not considered a consolidated entity in government-wide reporting under federal accounting standards and all activity with Federal Executive Boards must be reported as non-federal “N” activity for financial reporting purposes. Please refer to Appendix 1b for a list of Disclosure Entities, SFFAS No. 47.

4708.20—Additional Intra-governmental Reconciliation Requirements

The intra-governmental transactions reconciliation and resolution requirements are stated in OMB Circular No. A-136, revised.

4708.30—Federal Intra-governmental Transactions Accounting Scenarios

To aid in the reconciliation of intra-governmental differences, federal entities should follow the accounting scenarios found on the USSGL website. The scenarios provide posting logic for accounting transactions of select events occurring throughout the federal government and are made available as a source of guidance.

4708.30a—Non-fiduciary Transactions

For non-fiduciary transactions, OMB requires reporting entities to reconcile and confirm intra-governmental activity as well as balances quarterly for the following reciprocal groupings:

  • Services provided and reimbursables. Examples include, but are not limited to, legal, consulting, investigative, financial management, grants management, technology, reimbursables, and other similar services.
  • Cost of products sold. Examples include, but are not limited to, supplies, manufactured items, inventory, office space, and equipment/vehicle rentals.
  • Transfers, appropriations used, and collections for others, as well as unusual assets and liabilities related to appropriations. Examples include, but are not limited to, transfers between federal entities based on agreements or legislative authority, expended appropriations, taxes and fees collected, collections for others, receivables from appropriations, transfers payable, and custodial revenue.

4708.30b—Related to Capitalized Purchases and Assisted Aquisitions

Federal entities that purchase capitalized assets, or previously capitalized assets/inventory from other federal entities must follow the Capital Asset scenario located in Intra-governmental Capital Asset and Inventory Buy/Sell Transactions Guidance.

Federal entities that participate in Assisted Acquisitions must follow the Assisted Acquisition scenario located in Assisted Acquisition Guidance

4708.40—Intra-governmental Transactions Reconciliation and Resolution Process

Federal entities must use three-digit trading partner AID and a four-digit trading main account for all intra-governmental transactions. When federal entities report “appropriations transfers” within their departments, they must use their three-digit trading partner code. Federal entities should work with their federal trading partner to ensure the TP AID and TP Main Account are valid as well as applicable to the activity being monitored.

4708.40a—Fiscal Service Intra-governmental Activity

Federal entities are expected to work with their respective trading partners to reconcile and resolve intra-governmental differences. Appendix 5 discusses the reconciliation and resolution process which includes the Intra-governmental Root Cause, Corrective Action Plan (CAP), and dispute resolution processes.

In preparation for the year-end submission, federal entities should validate and reconcile their data monthly to resolve intra-governmental differences in certain reciprocal categories, prior to their data submissions in GTAS.

The data to reconcile consists of:

  • RC 07, Appropriation of Unavailable Trust or Special Fund Receipts (represented by GTAS Edit 33-UCAD Reciprocal Category 7 Transferred-In and Edit 34-UCAD Reciprocal Category 7 Transferred-Out),
  • RC 08, Non-expenditure Transfers of Unexpended Appropriations and Financing Sources (represented by GTAS Edit 35-UCAD Reciprocal Category 8 Transferred-In and Edit 36-UCAD Reciprocal Category 8 Transferred-Out),
  • RC 11, Non-expenditure Transfers of Financing Sources–Capital Transfers (represented by GTAS Edit 40-UCAD Reciprocal Category 11 Capital Transfers-In and Edit 41-UCAD Reciprocal Category 11 Capital Transfers-Out), Appropriations Received as Adjusted (represented by GTAS Edit 50-Normal Warrants Edit), and
  • RC 40, Fund Balance with Treasury (represented by GTAS Edit 1-Fund Balance with Treasury).

Significant entities and selected other entities (as designated by “**” in Appendix 1a) are required to explain and certify all Material Differences Reports (MDR) Parts I, II, and III for Quarter 1, Quarter 2, Quarter 3, and Year-end. Federal entities will use the Intra-governmental Module in GTAS to view and explain as well as certify their Material Differences.

The Material Differences Window, which is used to explain and certify differences will open after the GTAS Bulk File Submission Window closes. Federal entities may obtain the IGT Raw Data File from GTAS to be used for the research of differences. These dates are set by Fiscal Service. The intra-governmental key dates as well as the GTAS reporting window schedule can be found on the GTAS website.

Federal entities must provide detailed explanations for Material Differences Reports Parts I, II, and III-Z. Detailed explanations should include but are not limited to the following:

  • The reason the difference exists,
  • What is being done to reconcile the difference, and
  • The expected completion date of eliminating the difference.

If a federal entity is not able to provide the detailed information listed above, Fiscal Service may follow up for a response. Fiscal Service will use its own discretion when analyzing explanations and follow up for clarification, if needed.

Federal entities will also be able to obtain the following quarterly reports from GTAS:

  • Material Differences Report Part I (if applicable). This report displays differences equal to or greater than $100 million in all reciprocal categories (except RC 29, which is included in Part III). Federal entities will use subsection 4708.40b as guidance to select the explanation and the detailed information that must be provided.
  • Material Differences Report Part II (if applicable). This report displays differences equal to or greater than $10 million and less than $100 million in all reciprocal categories (except RC 29) with the following FR Entities that are encouraged to report for inclusion in the FR:
     
    • 0000 (Congress: House and Senate),
    • 0100 (Architect of the Capitol),
    • 0200 (U.S. Capitol Police),
    • 0300 (Library of Congress),
    • 0800 (Congressional Budget Office),
    • 0900 (Other Legislative Branches),
    • 1000 (The Judiciary), 
    • 2300 (U.S. Tax Court), and
    • 9999 (Unknown Trading Partners/Unidentified).

While a type of difference like those listed in subsection 4708.40b is not required for Material Differences Report Part II, a detailed explanation of the difference is expected. Federal entities must select “Part II Differences” as the type of difference when explaining these differences in the Intra-governmental Module of GTAS.

  • Material Differences Report Part III. This report displays amounts reported in RC 29 with the federal/non-federal domain value of Z for non-reciprocating intra-governmental activity. While a type of difference, like the types listed in subsection 4708.40b, is not required for Material Differences Report Part III, federal entities must select “Part III Differences” as the type of the difference. However, federal entities must provide Fiscal Service with an explanation of why this non-reciprocating intra-governmental activity is reported. An explanation of “non-reciprocating activity” is not considered acceptable. Fiscal Service needs the specific type of activity being captured in each USSGL (not mandatory until FY 2021). Fiscal Service may follow up for clarification to ensure the non-reciprocating intra-governmental activity reported is used for the appropriate purpose. 
  • Comparative Status of Disposition Report. This is available after all of Part I Material Differences are certified and the Material Differences Window is closed. It contains comparative MDR Part I reporting between the federal entity and its trading partners by Reciprocal Category. CFOs use this report to address and resolve inconsistencies in amounts and explanations between the federal entity and its trading partners.

With federal entities explaining and certifying material differences, the assurance for Fiscal Service that entities comply during the IGT reconciliation and resolution process is established using three functions:

  • Obtaining sufficient explanations and corrective actions, as applicable, to resolve the out-of-balance condition to obtain coverage for GAO assurance,
  • Obtaining assurance that federal entities are performing quarterly intra-governmental reconciliations and resolutions in accordance with OMB Circular No. A-136, revised, and Appendix 5, and
  • Ensuring federal entities are mutually completing the Intra-governmental Material Differences/Status of Disposition Certification Report for the same trading partner/Reciprocal Category material difference instances.

Note: Recurring differences should be limited to those situations that have been confirmed by the Fiscal Service.

4708.40b—Reporting Entity’s Explanation of Reporting in Material Differences Reports Part I

An explanation for Material Difference Part I reporting should be based on each identified difference in terms of the following categories:

(1)  Accounting/reporting error—occurs when the reporting entity has incorrectly reported activity either by reciprocal category, trading partner, or amount. The total of these amounts must be identified and explained. If the entity is in error, then provide the adjustment amount as well as the corrective action (journal entry, etc.), and when the error will be corrected.

(2)  Current-year timing difference—occurs when the reporting entity has reported activity in a different quarter than the trading partner reported the activity in the current-year. The total of these amounts must be identified. Explain whether an adjustment should be made.

(3)  Prior-year timing difference—occurs when a reporting entity has reported activity in a prior FY and the trading partner reported the activity in the current FY. The total of these amounts must be identified. Explain whether an adjustment should be made.

(4)  Accounting methodology difference—occurs when the reporting entity uses a different method than their trading partner to account for activity. The method of accounting must be identified and explained as well as attempt to provide the dollar amount of the difference caused by the differing methodologies.

(5)  Accrual methodology difference—occurs when the reporting entity uses a different accrual method than their trading partner to account for activity. The method of accrual must be identified and explained as well as attempt to provide the dollar amount of the difference caused by the differing methodologies.

(6)  Entity Verified—intended to indicate that a federal entity has verified its reported amounts and that the entity’s documents are in agreement with its quarterly source documentation; and the federal entity has confirmed that the policy and guidance related to transactions and balances have been followed. It also indicates the federal entity has reconciled this amount with its trading partner and knows why the difference, if any, exists. Selecting "Entity Verified" indicates that the trading partner accepts the onus for adjusting its amount to clear any difference going forward. Both federal entities cannot have Entity Verified where a difference exists. Federal entities should provide amounts and a detailed explanation to support the selection of Entity Verified.

(7)  Unidentified—occurs when the reporting entity cannot validate the amount of the difference or the trading partner at the time of reporting. The total of unidentified reporting amounts must be identified and explained as to why they are unidentified.

Note: Unidentified also can include instances where differences are due to existing guidance that is currently under review in order to ensure elimination at the government-wide level between trading partners when applied correctly (for example, judgment fund and FICA transactions).

4708.40c—Intra-governmental Transactions Metrics and Scorecards

Fiscal Service has implemented scorecards and metrics to track reporting differences government-wide by federal entity. Scorecards will be updated quarterly and disseminated to significant entities and other entities as determined by Fiscal Service. The purpose of the metrics is to monitor progress on resolving or explaining material intra-governmental differences. Refer to Appendix 5, subsection 2.4, for further information on the timeline for these scorecards and metrics as well as related federal entity requirements.

4708.50—Year-end Intra-governmental Reconciliation Process Related to GTAS

In accordance with OMB Circular No. A-136, significant entities and other entities should reconcile their intra-governmental balances with their trading partners and resolve all resulting differences prior to submitting their final GTAS ATB. Additionally, significant entities and their auditors should review the prior year-end scorecard to determine if a prior-year journal voucher was processed. If so, then the significant entity should identify the reason for the journal voucher as well as how to prevent the adjustment in the current year.

Reconciling data (reported as BETC in Central Accounting Reporting System) against Entity Reported Adjusted Trial Balance Data (reported in GTAS) can be done two ways. They are listed below. 

  • In GTAS, navigate to the MY ATB STATUS module and click on the Failed Edits Tab, click on View Details. This view defaults to Failed Fatal Edits (for example, Edit 1). Click on Proposed Analytical to review any Failed Proposed Analytical Edits.
  • Navigate to Run Reports Module, select Validations/Edits for Report Type, select either Failed Edits Detail or Failed Edits Summary (depending on needs), select the applicable reporting period information, run the report by Either User ID or Specified TAS, scroll down past Fatal Edits to find Proposed Analytical Edit Failures.

If no Failed Edits or Proposed Analytical Edits appear after GTAS ATB upload, then the data and ATB Data are reconciled, and no further action is necessary.

4708.60Year-end CFO Procedures for Intra-governmental Transactions/Balances

Significant entities must comply with the following instructions using the comparative, audited consolidated and department-level financial statements:

  • Provide responses to the representations outlined in the detailed “CFO Representation” instructions found in Appendix 4 for each intra-governmental issue, and
  • Ensure the data in the Intra-governmental Year-end Material Differences Reports are consistent with the information reported in the federal program entity’s financial statements.

Fiscal Service provides the CFO Representations Form for Intra-governmental Activity and Balances (including instructions) on the GTAS website.

Provide an electronic file of the CFO’s Representations for Intra-governmental Transactions and Balances along with any supporting documentation to the federal entity's IG, Fiscal Service, and GAO (see Figure 2 for due dates).

Section 4709—GTAS Requirements

GTAS requires reporting proprietary and budgetary USSGL account balances. Details can be found by visiting the GTAS website.

4709.10—GTAS System Access

To obtain system access, users may contact the GTAS Treasury Support Center.

4709.20—GTAS Reportable Data

The FR includes the data from the GTAS submissions for all federal entities into a set of reclassified financial statements. All federal entities must submit all changes to the reclassified financial statements through GTAS. Note the preference is to submit the changes through a resubmission of the ATB. If this is not possible, then adjustments should be submitted through the GTAS manual adjustment process. The GTAS data must reconcile to the federal entity’s audited AFR/PAR.

4709.30—GTAS Super Master Account File

The Super Master Account File (SMAF) contains the valid TAS balances and attributes for budgetary as well as proprietary ATB submission. 

Fiscal Service will be collaborating with entities to confirm attributes on the SMAF through the SMAF Attribute confirmation process which is new for FY 2020. Details can be found by visiting the GTAS website.

4709.40—Adjusted Trial Balance

Federal entities must prepare and submit pre-closing GTAS ATB at the TAS level using USSGL accounts and attributes. Non-executive federal entities that have not adopted the USSGL must crosswalk their general ledger accounts to the USSGL accounts before transmission.

The GTAS ATB must include USSGL accounts with the required attributes, and USSGL account balances must reflect the pre-closing adjusting entries needed to produce financial statements. The total sum of debit balances must equal the total sum of credit balances in the GTAS ATB. Report amounts in dollars and cents.

Significant entities and other entities must use the same USSGL data on the GTAS ATB that they use to prepare the current FY audited federal entity consolidated financial statements due to OMB. For detail on the specific requirements for the submission, please refer to the GTAS website. 

4709.50—General Fund Receipt Accounts

Federal entities that classify amounts on their Classification Transactions and Accountability (CTA) report in General Fund Receipt Accounts symbols using their three-digit agency trading partner AID also must submit a GTAS ATB, and must prepare federal entity financial statements that include the General Fund receipt activity.

4709.60—Treasury Managed Trust Fund Accounts

Fiscal Service’s Funds Management Branch provides the lead program entity a monthly GTAS ATB, or equivalent, for the Treasury managed trust fund activity located at Fiscal Service for each of the Treasury managed trust funds listed in Figure 3. The monthly GTAS ATB prepared by Fiscal Service contains collection and disbursement transactions that are recorded in the Treasury managed trust funds as well as investment activity and balances. The monthly GTAS ATB will be provided to the lead program entities no later than the fifth workday after the end of the applicable month. The program entities are responsible for recording appropriated amounts from the trust funds and reporting the final Treasury managed trust fund ATB in GTAS. 

Fiscal Service uses USSGL accounts from the USSGL TFM Supplement for current year reporting, with the proper attributes. The lead program entities identified in Figure 3 must include the Treasury managed trust fund ATB data in their GTAS Submission. Please email the Funds Management Branch with questions regarding the Treasury managed trust fund accounts to UTF@fiscal.treasury.gov.

4709.70—GTAS ATB Reports Transmission Methods

Each GTAS ATB preparer must submit the ATB data using the bulk file transfer method in GTAS. Federal entities must submit GTAS ATB for each active TAS (these include the TAS with no transactional activity but are active for CARS, see the Frequently Asked Questions for details). By certifying the GTAS ATB data, an entity is verifying the TAS is valid and its USSGL balances are accurate. For specific detail on GTAS ATB submissions, please refer to the GTAS website.

4709.80—Proprietary Balances in Canceled Accounts

GTAS will establish a default TAS (“C” domain value for availability type). The system-generated “C” TAS will have three components: the three-digit AID, availability type “C,” and a four-digit main account. The GTAS system will provide a “C” TAS on the GTAS Super Master Accounts File for each fund family represented on the SMAF. Federal entities may choose one or more “C” TAS on the SMAF to report assets. 

If a federal entity is using a default fund symbol of its own creation, they must use the new “C” account in its place. However, if federal entities are using a current-year fund symbol, an “X” fund, or some variation of an active account, they may continue. Federal entities may also decide on their own when to move these assets from the original purchasing fund but must be accomplished no later than the federal entity’s final GTAS submission for period 12 of the fifth FY after the availability has expired. 

Figure 2: Reporting and Submission Dates

July 30, 2020 Federal entities must submit unaudited interim financial statements, limited to the Balance Sheet, SNC, and SCNP to MAX.gov.
August 7, 2020 Fiscal Service will provide the federal entity technical experts the Significant Disclosures Template, final published version of note(s) from the prior-year FR identified as presenting a greater risk of failing to meet prescribed disclosure requirements, as well as auditor comments on each of these note(s) (if applicable) from the prior-year FR preparation process. See subsection 4704.10 for complete details.

*August 20, 2020

Significant entity IGs must submit the interim Legal Representation Letters and Management Schedules (using the Management Schedule template provided by Fiscal Service) to Fiscal Service, DOJ, and GAO.

September 2, 2020

In accordance with OMB Circular No. A-136, Section IV.2, federal entities must submit:

  • Variance analysis
  • Unaudited notes. SIRA must include updates to social insurance with this requirement.

In addition, federal entities must submit:

  • Completed Budget Deficit Reconciliation template
September 4, 2020 Federal entity technical experts are required to provide feedback on the Significant Disclosures template as well as any narrative updates from prior-year FR. See subsection 4704.10 for complete details.

October 6, 2020

GTAS opens for September 30, 2020, ATB submission.

October 16, 2020

GTAS expenditure TAS must be certified by 5 p.m. ET.

October 26, 2020

DOL reports the draft Social Insurance data for Black Lung and Unemployment Insurance, and RRB reports the draft Social Insurance data for Railroad Retirement to MAX.gov.

November 5, 2020 GTAS Period 12 Revision window closes at 5 p.m. ET.

November 13, 2020

GTAS Period 12 Extension window closes at 2 p.m. ET. Please contact Fiscal Service if there are any adjustments needed to GTAS data after November 13, 2020.

November 16, 2020 Year-end Material Differences Reports (MDRs) are available in GTAS to be explained and certified. The Raw Data File is also available in GTAS.
November 20, 2020 DOJ will provide the interim government-wide Legal Representation Letter to GAO, OMB, and Treasury.
December 1, 2020 Federal entity technical experts are required to provide feedback on the Significant Disclosures template as well as any narrative updates from prior-year FR. See subsection 4704.10 for complete details.
December 1, 2020
Federal entity CFOs submit their Representations for Intra-governmental Activity and Balances to the entity's IG and Fiscal Service. All year-end MDRs must be certified in GTAS by 5 p.m. ET.
*December 30, 2020 Final AFRs and PARs are due to MAX.gov and also by email to GAO by 6 p.m. ET. Entities should take all reasonable steps needed to meet the November 16 due date, however if this is not feasible, they may publish their AFRs and PARs no later than December 30, 2020. Please contact Fiscal Service if there are any AFR/PAR adjustments after December 30, 2020.
*December 30, 2020

1. Significant entities must submit a variance analysis in accordance with OMB Circular No. A-136, Section IV.2.

2. Significant entities must submit a completed Budget Deficit Reconciliation template via the MAX.gov website. (Please see subsection 4705.10)

3. Significant entity IGs must submit the final Legal Representation Letter and Management Schedules (using the Management Schedule template provided by Fiscal Service) to Fiscal Service, DOJ, and GAO by 6 p.m. ET.

4. Significant entities must submit the Management Representation Letter in conjunction with the Uncorrected Misstatements (SUM) via email to Fiscal Service and GAO. Upload the required documents to OMB via the MAX.gov website (Please see Section 4706).

January 12-19, 2021

Federal entity FR review period. Comments are due by close of business.

March 3, 2021

Significant entity IGs must provide Fiscal Service information relating to subsequent events that occurred from the effective date of their final Legal Representation Letters through February 26, 2021. Send this information via email to Fiscal Service, DOJ, and GAO.

March 5, 2021 DOJ will provide the final government-wide Legal Representation Letter to GAO, OMB, and Treasury.

March 16, 2021

Significant entity CFOs must provide Fiscal Service information about subsequent changes to Management Representation Letters and financial statements that have occurred from the date of the financial statement's audits through March 15, 2021. Send this information by noon via email to Fiscal Service, Treasury (Main), OMB, and GAO.

March 25, 2021

Financial Report of the U.S. Government is published.

* Represents the “no later than date.” Federal entities should submit data as early as possible.

Intra-governmental Key Dates may be found on the GTAS website.

GTAS Deadlines may be found on the GTAS website.

Figure 3: Treasury Managed Trust Funds

Treasury Managed Trust Fund

Federal Entity/Department

Federal Supplementary Medical Insurance

Department of Health and Human Services (HHS)

Federal Hospital Insurance

HHS

Vaccine Injury Compensation

HHS

Federal Old-Age and Survivors Insurance

Social Security Administration (SSA)

Federal Disability Insurance

SSA

Airport and Airway

Department of Transportation (DOT)

Sports Fish Restoration and Boating

Department of the Interior

Oil Spill Liability

Department of Homeland Security

Highway

DOT

Black Lung Disability

Department of Labor (DOL)

Unemployment

DOL

Hazardous Substance Superfund

Environmental Protection Agency (EPA)

Leaking Underground Storage Tank

EPA

Inland Waterways

U.S. Army Corps of Engineers

Harbor Maintenance

U.S. Army Corps of Engineers

South Dakota Wildlife Restoration

U.S. Army Corps of Engineers

Patient-Centered Outcomes Research

Independent Agency

U.S. Victims of State Sponsored Terrorism Fund Department of Justice

 

Contacts

Direct inquiries and deliver documents required by this chapter to:

Jaime Saling, Director
Financial Reports and Advisory Division
Fiscal Accounting
Bureau of the Fiscal Service
PO Box 1328
Parkersburg, WV 26106-1328
Telephone: 304-480-6485
Fax: 304-480-5176
Email: financial.reports@fiscal.treasury.gov

Also, deliver documents required by this chapter to:

Carolyn Voltz, CPA
Government Accountability Office
441 G Street, NW, Room 5X23
Washington, DC 20548
Telephone: 202-512-5422
Email: USCFS@gao.gov

Carol S. Johnson, Policy Analyst
Office of Management and Budget
Office of Federal Financial Management
725 17th Street, NW
Washington, DC 20503
Telephone: 202-395-3993
Email: csjohnson@omb.eop.gov
MAX.gov website 

Scott Bell, Senior Staff Accountant
Office of the Fiscal Assistant Secretary
Department of the Treasury
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Telephone: 202-622-1797
Email: robert.bell@treasury.gov

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Appendices Listing

Appendix No.

Title

1a

Federal Trading Partner Codes for the Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS)

1b Determination of Consolidation Entity, Disclosure Entity, or Related Party for the Governmentwide Treasury Account Symbol Adjusted Trial Balance System (GTAS)
2

Reciprocal Categories Crosswalk to Financial Statements

3

Intra-governmental Transactions (IGT) Categories of Reciprocal U.S. Standard General Ledger (USSGL) Proprietary Accounts

4

CFO Representations for Intra-governmental Activity and Balances Instructions

5

Overall Intra-governmental Transactions (IGT) Processes and General Information 

6

Intra-governmental Transactions (IGT) Investments and Borrowings

7 Intra-governmental Transactions (IGT) Benefits
8 Intra-governmental Transactions (IGT) Buy/Sell
9 Intra-governmental Transactions (IGT) Transfers
10 Intra-governmental Transactions (IGT) Custodial & Non-Entity Transactions
11 Recording Intra-governmental Transactions with the General Fund of the U.S. Government

Appendices are available on the PDF version only.